ML20199E102

Draft B,Rev 0 to Guide on Evaluation of Safety Significance

ML20199E102
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Site:	Comanche Peak
Issue date:	02/28/1985
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
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References
FOIA-86-36 PROC-850228-01, NUDOCS 8606230184
Download: ML20199E102 (5)

Text

C da ca Evclusti:n DRAFT: B

Ofcty Significznca Revision

0 02/28/85 Page 1 of 4 l 1.0 PURPOSE -

l This Guide provides a description of an acceptable manner for i Review Team Leaders (RTLs) to conduct and document the safety significance evaluations that are required by the CPRT Program Plan.

2.0 PROGRAM PLAN REQUIREMENTS Thef[211ovingisasummaryoftherequirementscontainedinthe Program Plan concerning evaluation of safety significance. This summary provides general background information for this Guide and l does not modify or replace the requirements in the Program Plan.  !

The Program Plan requires an evaluation of the safety significance 8 of identified deficiencies. As used in this context, " identified a deficiencies" includes those identified by the NRC-TRT in their ,

definition of the item and shown to be deficiencies after  !

investigation by the CPRT and those identified by the CPRT in the conduct of Action Plans. The deficiencies covered by this requirement include specific technical deficiencies and generic /prograc:matic deficiencies. In the case of specific technical deficiencies the evaluation of safety significance aids ,

in the development of approprince corrective action. For generic l or programmatic deficiencies the evaluation of safet/ significance not only facilitates the definition of appropriate corrective action but also facilitates the definition of appropriate expanded i reviews. In either casa the objective of an evaluation of safety significance is the determination of the extent to which the i deficiency would have affected the functioning of the system, i structure, or component in which the deficiency exists. The evaluation of safety significance serves as an input to the evaluation of collective significance. The results of the evaluations of safety significance are to be documented in the Action Plan Results Report.

3.0 REPORTABILITY The evaluation of safety significance is not intended to determine whether a det'iciency must be reported to the NRC. Determination of the reportability of identified deficiencies is the responsibility of TUCCO. The criteria for determining whether a deficiency has i safety significance is different from the criteria used for reportability under 10CFR 50.55(e).

4.0 CRITERIA FOR SAFLTY SIGNIFICANCE For the purposes of the CPRT a deficiency is considered significant i if after evaluation any of the following conditions are met: '

The uncorrected condition would have resulted in a violation of a Technical Specification for any mode of operation.

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Cuida cn Evclustian DRAFT: B cf Scfcty Significcnco R vision: 0 02/28/85 Page 4 of 4 j 6.0 COMPARISON AGAINST REPORTABILITY REQUIREMENTS - (Cont'd) .

A significant deviation from performance specifications which will require extensive evaluation, extensive redesign, or extensive evaluation, extensive redesign, or extensive repair to establish the adequacy of a structure, system, or component to meet the criteria and bases stated in the safety analysis report or construction permit or to otherwise establish the adequacy of the structure, system, or component to perform its

, intended safety function.

The above bases are not the bases for safety significance determinations, but only for reportability.

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Cuida en Ev:1uatian DRAFT: B cf Scf0ty Significenen Revision: 0 02/28/85 Page 2'of 4 4.0 CRITERIA FOR SAFETY SIGNIFICANCE - (Cont'd) -

The uncorrected condition would have resulted in the failure of a system, structure, or component important to safety to function when and as required.

The uncorrected condition would have resulted in a system, structure, or component important to safety that fails to meet its design bases as stated in the FSAR such that physical rework, repair or replacement is required.

The uncorrectef condition would have resulted in a violation of the requi. ments of 10CFR related to the functioning of systems, structures, or components important to safety.

5.0 EVALUATION OF DEFICIENCIES Each identified deficiency should be evaluated with respect to its safety significance. In making this assessment Review Team Leaders should consider:

The function of the system, structure, or component in which the deficiency exists.

Whether alternative systems, structures, or components exist

, that would achieve the required safety function.

Whether the deficier.cy results in a significant increase in the probability of occurrence or the consequences of an accident or malfunction evaluated in the FSAR.

Whether the deficiency results in the possibility of an accident or malfunction different from those evaluated in the FSAR.

Whether the deficiency results in a significant reduction in the margins of safety associated with any technical specification.

Whether planned reviews or tests would have found the deficiency prior to the time at which the system, structure, or component would have been required to perform its safety function.

If the deficiency is generic or programmatic in nature, whether the deficiency resulted in a combination of component level functional defects that, taken together, reduce the degree of protection afforded the public.

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• Cuida (n Evaluati:n DRAFT: B cf S:fcty Significccca Revicien: 0 02/28/85 Page I of 4 j 5.0 EVALUATION OF DEFICIENCIES - (Cont'd) -

Each evaluation should define the deficiency in detail and state whether the evaluation is of the specific deficiency, a generic or programmatic deficiency, or both. The evaluation should use the above list of factors plus any others determined by the Review Team Leader to be appropriate to characterize the deficiency. The comparison against these factors should be documented. Based upon this comparison the evaluation should document a determination of

. the safety significance of the deficiency relative to the criteria in Section 4.0 of this Guide.

6.0 COMPARISON AGAINST REPORTABILITY REQUIREMENTS As noted in Section 3.0 above, this Guide does not address reportability requirements and it is not the responsibility of the CPRT to make the determination of the reportability of any deficiency. However, it is useful for Review Team Leaders to recognize the difference between the safety significance evaluation and the reportability requirements of 50.55(e). Items may be reportable under 50.55(e) without being safety significant under the CPRT Program Plan. For example an approved design for a component may not conform to one or more criteria contained in the FSAR, but the component may still be capable of performing its safety functions based upon an evaluation. In such a case the t deficiency may be reportable but would not have safety significance. Another example could be a breakdown in QA such as in the inspection program that is evaluated not to have involved attributes important to system, structure, or component functions.

Again this may be reportable, but would not have safety significance.

For information only, the following are the bases listed in 10CFR 50.55(e) for repcreability:

A significant breakdown in any portion of the quality assurance program conducted in accordance with the requirements of Appendix B to this part; or A significant deficiency in final design as approved and released for construction such that the design does not conform to the criteria and bases stated in the safety analysis report or construction permit; or A significant deficiency in construction of or significant damage to a structure, system, or component which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in the safety analysis report or construction permit or to otherwise establish the adequacy of the structure, system, or component to perform its intended safety function; or

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t OFFICE MEMORANDUM TO: Review Team Leaders FROM:

Jenior Review Team DATE: January 30, 1985

SUBJECT:

Guide for Safety Significance Evaluations Attached is a guide for performing evaluations of safety significance when rcquired by the Program Plan. The Senior Review Team has reviewed this guide cnd determined that its use will satisfy Program Plan requirements. Review Team Leaders may use alternative methods of meeting Program Plan requirements.

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